UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

United States,
                
      v.                         Cr. Nos. 87-63,
                                 Judge Charles R. Richey
Ellen Thomas,	
	Defendant,	

MOTION TO RESCHEDULE HEARING ON DEFENDANT'S MOTION
TO RECONSIDER AND/OR SENTENCING

According to a Notice, signed by Joe Burgess and filed on January 16, 1988, "hearing on motion for reconsideration and/or sentencing" is scheduled for January 28, 1988. Pursuant to Local Rule 311 defendant hereby moves the Court to reschedule those matters.

DISCUSSION

In relevent part Local Rule 311.2 provides:

"(a) Not less than 27 days prior to the date set for the sentencing, the probation officer shall disclose the initial presentence report to the defendant...."

As of January 24th, 1988 the presentence report in this case had not been made available for review by the defendant. Defendant has had no opportunity to confer with the Ms. Robinson, the probation officer, and Ms. Robinson does not plan to be in court for the sentencing. Public Gathering Permit with with Mr. Hunter.

It may seem that the appearance of justice would best be served only if the defendant has had a reasonable period of time in advance of her sentencing to review, confer with the probation officer, and submit written objections to such factual disputes as may remain. As this matter is presently scheduled defendant will be hard pressed to prepare for her sentencing. SEE, Local Rule 311, generally.

CONCLUSION

Therefore defendant urges the Court to apply the twenty-seven day standard of Local Rule 311, and to reschedule the proceedings presently set for January 28, 1988 accordingly.

A proposed Order is attached.

Respectfully submitted,

Ellen Thomas, Defendant,
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005

CERTIFICATE OF SERVICE

I, William Thomas, hereby certify that a copy of the foregoing Motion To Join The Motion To Reschedule Sentencing was served upon Assistant U.S. Attorney Mark Dubester, Judiciary Square, 555 4th Street, NW, Washington, D.C., 20001, by hand on this 21st day of January, 1988.

(signed)